## ... FROM: Rodney Nordstrom 201 W. McClure Peoria, IL 61604 Tel: 309-685-2326 Email: jurydoctor@sbcglobal.net

TO: DOCKET OPERATIONS ROOM W12-140 OF THE WESTBUILDING GROUND FLOOR ' 1200NEWJERSEY AVENUE, SE. WASHINGTON, DC, 20590 RegulatoryDocketNo.

_____ _

PETITION FOREXEMPTION OF: Rodney Nordstrom •.• r •

...,,... 0- I , ... I 0

**~** "/ j J l .I i
-

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTSOF TITLE 14 OF THE CODE OF FEDERALREGULATIONS PART21, SUBPART HAND SECTIONS§§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI PHANTOM 3 Advanced UNMANNED AIRCRAFTSYSTEMS PURSUANTTO:SECTION 333 OF I THE FAAMODERNIZATION

### AND REFORM ACT OF2012 (PUBLIC L}\

### W1

### i 2-95)

Submitted on November 3,2015

Rodney Nordstrom for Peoria Area Drone Videography Page 1

### ..,


### TABLE OFCONTENTS GLOSSARY OF ABBREVIATIONS

............................................................................................ 3

### S~Y**~·················5··~·······················,.······························~································-································~····**4 

### IN1RODUCTION AND INTERESTS OFPETITIONER

......................................................... 

### 4 BACKGROUND

......... ...........: .. ..................................................................................................4 BASIS FOR PETITION

............................................................................................................. 5 NAME AND ADDRESS OFPETITIONER

.............................................................................. 7 THE SPECIFIC SECTIONS OF 14 

### C.F.R. FROM WHICH Rodney Nordstrom SEEKS EXEMPTION

............................................................................................................................. 

### 8 THE EXTENT OF RELIEF Rodney Nordstrom SEEKS AND THE REASON Rodney Nordstrom SEEKS THE**RELIEF.;~**

### ....**~** 

### ............. ...................................11 

### THE REASONS WHY GRANTING Rodney NordstromREQUEST WOULD BE IN THE PUBLIC INTEREST

........· ......· ............................................................ 1

### S THE REASONS wHY GRANTING THE EXEMPTION WOULDNOT ADVERSELYAFFECTSAFETY

..................................................................................................... 19 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

........................ 33 

### ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS CONCLUSION

..........................................................................................................................33

Rodney Nordstrom for Peoria Area Drone Videography Page2AGL AOI ATC ATO AV CFR COA FAA 

## FAR GCS GPS LOL NAS NOT AM PIC Section 333 

## so SOP UA UAS VFR VLOS VMC VTOL GLOSSARYOFABBREVIATIONS

Above Ground Level Area ofInterest Air Traffic Control Air Traffic Organization Aerial Vehicle

Code ofFederal Regulations Certificate of Authorization FederalAviationAdministration Federal AviationRegulation Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice toAirman Pilot In Command FAAModernization and Reform Act of2012 (FMRA) Section333 Safety Observer Standard Operating Procedures UnmannedAircraft Unmanned Aircraft System Visual Flight Rules ·· Visual Line 1 ofSite Visual Mete,orological Conditions Vertical Takeoffand Landing

Rodney Nordstrom for Peoria Area Drone Videography Page3

### SUMMARY RodneyNordstrom (Peoria Area Drone Videography) seeks exemptionfrom the requirements of 14 C.F.R 

### §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a) (2), and 91.417(a) & (b), to operate an Unmanned Aircraft Systempursuantto Section 333 ofthe FAAModernizationand ReformAct of2012 (FMRA). This exemption will permit Rodney Nordstrom to operate anUnmanned Aircraft System (UAS) for the commercial purposeofconducting aerial video and photographyofRealEstate Properties (for homeowners, realtors, horny builders, home contractors and 

### I orhomeinspectorsfor real estate marketingand inspection ofhome exteriors), inspection offarm land, railroad and emergency concerns, as well
as filming ofspecial events,

### fil~ sets over certain areas ofthe United States. 

### INTRODUCTIONAND INTERESTS OF

### THE PETITIONER Rodney Nordstrom owner of Peoria Area Drone Videography which is a production company based in Illinois specializing in real estate videography, photography, video production, and special eventproduction. Theprincipals ofRodneyNordstrom (Peoria Area Drone Videography) have been in the video and entertainment production business 5 years. Rodney Nordstrom's objective is to conductaerial photography and videography in orderto provide high quality digital imaging and video contentto its clients, in particular to homeowners, real estate agepts, realtors, home builders,homecontractors, and/orhome inspectors for real estate marketing and inspections ofhomeexteriors as well as filming ofspecial events, film sets, landscape, aerial mapping, surveying utilizingDll Phantom 

### 3 UAS. More specifically, Rodney Nordstrom aerial video and photography operations will serve inthe following areas:
• Aerial photography ofhouses I residential and commercialbuildings and power lines

• Aerial videography ofhouses I residential and commercial buildings and powerlines

• Aerial eventphotography

• Aerial event filming

• Aerial videography ofrail road tracks and bridges
• Aerial videography offarms and farmland

• Increase public knowledge ofUAS and promote safe UASoperations
Rodney Nordstrom for Peoria Area Drone Videography Page4Theproposed aerial filming will be conducted over private property with controlled access in the NAS and withthe knowledge and permit oftheprivate property's owner. Unmanned Aircraft Systems; DJIPhantom 3 Advanced UAS Rodney Nordstrom seeks an exemption to operate DJI systems DRONES for compensation
or hire within the NAS. The DJI Phantom 3 Advanced is a vertical takeoffand landing (VTOL) UnmannedAircraft (UAS) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 3 Advanced UAS has a maximum gross weight of approximately 2 pounds 11 ounces, while having a length of 16 inches width of 16 inches, height of8 inches, and a maximum speed ofapproximately 29 knots. DJI Phantom 3 Advanced UASis equipped with four main rotors; driven by Lithium Polymer battery powered electricmotors. The DJI Phantom 3 Advanced UAS that will be operated by a licensed pilot, will be registered in accordance with 49U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked 

### inaccordance with 14 C.F.R. Part 45, Identification and RegistrationMarking. 

### BASIS. FORPETITION Petitioner, Rodney Nordstrom, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization andReform Act of 2012 (FMRA), Section 333, Special Rules for Certain UnmannedAircraftSystems, hereby petitions the Administrator to conunercially operate the DJI Phantom 3 Advanced UAS in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.109, 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). In consideration ofthe speed, weight, size, and limited operating area associated withthe unmanned aircraft and its operation, Rodney Nordstrom's operation ofDJI Phantom 3 Advanced UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Rodriey Nordstrom requests 

### in relieffrom Sections 91.405(a),91.407(a)(l), 91.409(a)(1) &.(a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.

Rodney Nordstrom for Peoria Area Drone Videography PageSRodney Nordstrom submits that the requested reliefis proper since anequivalent level ofsafety will be ensured. Rodney Nordstrom will use only experienced personnel or technicians to perform maintenance, alterations, orpreventive maintenance on the UAS using the methods, techniques, and practicesprescribed inthe operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual). Furthermore, Rodney Nordstrom will document and maintain all maintenancerecords for the DJI Phantom 3 AdvancedUAS. Relieffrom certain requirements ofSection 61.113(a) and 

### (b), entitled 

### Privatepilotprivileges 

### and limitations: Pilot In Command, is requested by Rodney Nordstrom to the extent necessary to allow a Pilot in Command (PIC) holding a Supplemental PilotCertificate, and who has demonstrated, by meeting minimum flight- hour and currencyrequirements, that the PIC is able to safely operate the DJI Phantom 3 Advanced UAS ina manner consistent with this exemption, including evasive and emergency maneuversand maintaining appropriate distances from people, vessels, vehicles and structures. Rodney Nordstrom seeks relieffrom Section 91.7(a), entitled 

### Civil aircraft airworthiness, because the DJI Phantom 3 Advanced UAS does not requirean airworthiness certificate in accordance with 14 C.F.R Part 21, SubpartH. As such, Rodney Nordstrom submits that he will ensurethat the DJI Phantom3 Advanced UAS is in an airworthy condition, prior to every flight, by determining,thatthe UAS's is in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual), and thatthe aircraft is in a condition for safe flight. Rodney Nordstrom also seeks an exemption from the requirements ofSection 91.121, entitled

### Altimeter Settings, as the DJI Phantom 3Ad:vancedUAS will not have a typical barometric altimeter onboard. However, altitude information ofthe DJI Phantom 3 Advanced UAS will beprovided to the PIC viaGlobal Positioning System (GPS) equipment and radio communications telemetry data link,which downlinks from the UAS 

### to the GCS for active monitoring ofthe flight path. This altitude information, , combined with Rodney Nordstrom's operation ofthe DJJ Phantom 3 Advanced UAS within visual line ofsight, at or below 200 feet AGL, will ensurea level ofsafety equivalent to Section91.121.

Rodney Nordstrom for Peoria Area Drone Videography Page6Additionally; Rodney Nordstrom seeks an exemption from the requirementsofSection 91.151(b), entitled

### Fuel requirements for flight in VFR conditions. Rodney Nordstrom submi1s that safety will not be affected by operation ofthe DJIPhantom 3 AdvancedUAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough batterypowerto fly for a total duration ofapproximately 13.5 minutes to the first point of inten,ded landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, Rodney Nordstrom provides the following information in support of his petition for exemption: 

### A. Name AndAddress Of The Petitioner. The name and address ofthe Petitioner and point ofcontactis: Rodney Nordstrom· 661 S. Ridgeview Ln. Peoria, IL 61604 Tel:**~09-369-7067** Email: iurydoctor@sbcglobal.net 

### B. The Specific Sections Of 14 C.F.R. From Which RodneyNordstrom Seeks Exemption. 1. Rodney Nordstrom Seeks Exemption From The Requirements Of Section 61.113(a) And (b). Section 61.113, entitled Private pilot privileges and limitations: Pilot in corninand, subsections (a) and (b) prescribethe following, in relevantpart: (a) No person who holds a privatepilot certificate may act as 

### a: pilot incommand (PIC) ofan aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC ofan aircraft. (b) A private pilot may, for compensation or hire, act as PIC ofan aircraftin connection with any business or employment if.- (1) The flight is only incidental to that business or employment;and (2) The aircraft does not carry passengers orproperty for compensation or hire. Rodney Nordstrom for Peoria Area Drone Videography Page7

## .. 2. Rodney Nordstrom Seeks Exemption From The Requirements OfSection91.7(a). Section 91.7, entitled Civil aircraft airworthiness, subsection (a}, states the followh1g: (a) No person may operate a civil aircraft unless it is in an airworthy condition. 3. Rodney Nordstrom Seeks Exemption From The Requirements OfSection 91.121. Section 91.121, entitled Altimeter settings, subsection (a}, states the following, inpart: (a) Eachperson operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating-- (1) Below 18,000 feet MSL, to-- (i)The current reported altimeter setting ofa station along the route and within 1 00 nautical miles oftheaircraft; (ii)Ifthere is no station within the area prescribed in paragraph (a)(1 )(i)of this section, the current reported altimeter setting ofanappropriate available station; or (iii)In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. 4. Rodney Nordstrom Seeks Exemption From The Requirements OfSection 91.151(b). Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft under VFR conditionsunless (considering wind and forecast weather conditions) there is enough fuel tofly to the first point ofintended landing and, assuming normal cruising speed,to fly after that for at least 20 minutes. 5. Rodney NordstromSeeks Exemption From The Requirement Of Section 91.405(a). Section 91.405, entitled Maintenance required, subsection (a), states thefollowing: Each owner or operator ofanaircraftRodney Nordstrom for Peoria Area Drone Videography Page 8

## .. (a) Shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in part 43 ofthis chapter. 6. Rodney Nordstrom Seeks Exemption From The Requirements Of Section 91.407(a)(l) Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alterationunless-- (1) It has been approved for return to service by a person authorized under§ 43.7 ofthis chapter. 7. Rodney Nordstrom Seeks Exemption From The Requirements Of Sections 91.409(a)(l) And 91.409(a)(2). Section 91.409, entitled Inspections, subsection (a), states thefollowing: (a) Except as provided in paragraph (c) ofthis section, no person may operatean aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 ofthis chapter andhas been approved for return to service by a person authorized by § 43.7ofthis chapter; or (2) An inspection for the issuance ofan airworthiness certificatein accordance with part 21 ofthis chapter. 8. Rodney Nordstrom Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b). Section 91.417, entitled Maintenance records, subsections (a) and (b), statethe following: (a) Except for work performed in accordance with§§ 91.411 and 91.413,each registered owner or operator shall keep the following records for theperiods specified in paragraph (b) ofthis section:

Rodney Nordstrom for Peoria Area Drone Videography Page9(1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and eachengine, propeller, rotor, and appliance ofan aircraft. The records must include-- 

### (i)A description (or reference to data acceptable to the Administrator) of the work performed; and (ii)The date ofcompletion ofthe work performed;and (iii)The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service ofthe airframe, each engine, eachpropeller, and each rotor. (ii)The current status oflife-limitedparts ofeach airframe, engine, propeller, rotor, and appliance. (iii)The time since last overhaul ofall items installed onthe aircraft which
are required to be overhauled on a specified timebasis. The current inspection status ofthe aircraft, including the time since the last inspection required by the inspection program under whichthe aircraft and its appliances aremaintained. (iv) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the ADor safety directive number and revision date. Ifthe AD or safetydirective involves recurring action, the time and date whenthe next action is required. (v) Copies ofthe forms prescribed by§ 43.9(d) ofthis chapter foreach major alteration to the airframe and currently installed engines,rotors, propellers, and appliances. (vi) Copies ofthe forms prescribed by §43.9(d) ofthis chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
Rodney Nordstrom for Peoria Area Drone Videography Page 10(b) The owner or operator shall retain the following records for theperiods prescribed: (1) The records specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) ofthis section shall be retained and transferred withthe aircraft at the time the aircraft is sold. (3) A list ofdefects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraftis approved for return to service. 

### C. The Extent Of Relief RodneyNordstrom SeeksAnd The Reason ·· Rodney Nordstrom Seeks The Relief. 1. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney Nordstrom Seeks ReliefFrom Section 61.113(a) And(b). Relieffrom Section 61.113(a) and (b) entitled Private pilot privilegesand limitations: Pilot in command, is requested to the extent necessary to allow aPIC holding a SupplementalPilot Certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for compensationor hire. This reliefis requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC ofan aircraft in connection with any business or employment if: (1) The flight isonly incidental to that business or employment; and (2) The aircraft does not carry passengers orproperty for compensation orhire. As set forth more fully below, Rodney Nordstrom submits that an equivalent level ofsafety will be maintained because no PIC will be allowed to operate the Phantom 3 Advanced UAS unless that PIC has metcertain flight-hour and currency requirements, demonstrating that the PIC isable to safely operate either the Phantom 3 Advanced UAS in a manner consistent with the operations specifications as described inthis exemption, including evasive and emergency
Rodney Nordstrom for Peoria Area Drone Videography Page 11maneuvers, as well asmaintaining appropriate distances from people, vessels, vehicles and structures.Further) Rodney Nordstrom submits that all flights of

### the DJI Phantom3 Advanced UAS, conducted bythe PIC pursuant to the grant of this Petition: (1) will be incidental to Rodney Nordstrom's business; and (2) 

### will not carrypassengers orproperty for compensation orhire. Rodney Nordstrom believes that though UAS are not traditional aircrafts, a PIC operating the UA must have knowledge ofAirman rules, basic Airspace and comply with allthe rules proposed by the FAA. However, considering the fact that a UA is almost like a toy, weighing less than a skinny person, the PIC may be exempt from obtaining a Private Pilot Certificate, a Sports Certificate,a Recreational Certificate considering these certificates require flight hours of several thousand tons weighing aircrafts. The operation ofUAS by Rodney Nordstrom is strictly for commercial/entertainment 

### I informational purposes, thus the operatorsofthe UAS have a career and 

### I orfreelance employment as a Camera Operator and Cinematographer and will be not be entertaining a career
as a pilot. Lastly, the UAS will operate no higher than 200 feet, consequently causing no danger do any other aircraft in theNAS.

2. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney Nordstrom Seeks ReliefFrom Section 91.7(a). Relieffrom Section 91.7(a) entitled Civil aircraft airworthiness, is requestedto the extent required to allow Rodney Nordstrom to determine that the DJI Phantom 3 Advanced UAS is in airworthy condition prior to every flight by ensuring that the UAS is in compliance withtheoperating documents (i.e., the Aerial Drone Media Operations Manual, Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual). Rodney Nordstrom seeks the requested reliefbecausethe DJI Phantom 3 AdvancedUAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Rodney Nordstrom will ensure that theDJI Phantom 3 Advanced UAS is in airworthy condition based upon its compliance with the operating documents (i.e., Monthly

Rodney Nordstrom for Peoria Area Drone Videography Page 12Maintenance Log, andDJI Phantom 3 Advanced Instruction Manual) priorto every flight, and further, determine thatthe aircraft are in condition for safe flight,
as stated in the conditions and limitations below. 3. Extent OfRelief Rodney Nordstrom Seeks And The Reason Rodney Nordstrom Seeks ReliefFrom Section91.121. Relieffrom Section 91.121, entitled Altimeter settings, may be required to allow flight operations ofthe DJI Phantom 3 AdvancedUAS, which utilize
a barometric pressure sensor, GPS equipment, and aradio communications telemetry data link to downlink altitude information from the UA to the PIC at the ground control station (GCS). Since the FAA requires thatany altitude information concerning UAS operations be reported to air trafficcontrol (ATC) in feet above ground level (AGL), Rodney Nordstrom seeks the requested reliefbecause the Phantom 3 AdvancedUAS's altimeter may be set on the ground to zero feet AGL, rather than the local barometricpressure orfield altitude, before each flight. Considering the limited altitude ofthe proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditionsand limitations stated below. As more fully set forth herein, an equivalent level ofsafety will be maintained since the DJI Phantom 3 Advanced UAS are equipped with abarometric pressure sensor and GPS equipment, which automatically ensures that aground level pressure setting will be establishedpriorto each flight, and provides the PIC with altitude information ofthe UAon the heads-up display ofthe GCS. 4. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney Nordstrom Seeks ReliefFrom Section91.151(b). Relieffrom Section 91.151(b) entitled Fuel requirements for flight inVFR conditions, is requested to the extent required to allow flights ofthebattery powered DJI Phantom 3 Advanced UAS duringdaylight hours in visual Rodney Nordstrom for Peoria Area Drone Videography Page 13meteorologicalconditions (VMC), under visual flight rules (VFR), for a total duration of 13.5 minutes to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Rodney Nordstrom seeks the requested reliefbecause without anexemption from Section 91.151 

### (b), the flight time duration ofthe battery powered DJI Phantom 3 Advanced UAS will severely constrain the practicality of any aerial video or still photo flight operations that Rodney Nordstrom proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications ofthe DJI Phantom 3 Advanced UAS operating documents, and Rodney Nordstrom proposed operating limitations, ensure that safe operation of the battery powered DJI Phantom 3 Advanced UAS during daylight hours invisual meteorological conditions 

### (VMC), under visual flight rules (VFR), withenough battery powerto fly for a total duration of 13.5 minutes to the first pointofintended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 5. Extent OfReliefRodney Nordstrom Seeks And The Reason Rodney Nordstrom Seeks ReliefFrom Section 91.405(a), 91.407(a)(l), 91.409(a)(1) & (a)(2), And 91.417(a) & (b). Since Sections 9L405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a)& (b) only apply to aircraft with an airworthiness certificate, Rodney Nordstrom requests relieffrom these Sections because the DJI Phantom 3 AdvancedUAS doesnot require airworthiness certificates. As set forth more fully below, the 

### DJI Phantom 3 Advanced UAS meetsthe conditions ofFMRA Section 333 for operation without anairworthiness certificate. Accordingly, Rodney Nordstrom will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS usingthe methods, techniques, and practices prescribed in the UAS operating documents (i.e., the Rodney Nordstrom Aerial Operations Manual, Monthly MaintenanceLog, and DJI Phantom 3 Advanced Instruction Manual). Furthermore, Rodney Nordstrom will document and maintain all maintenance records for the DJI Phantom 3 Advanced UAS.

Rodney Nordstrom for Peoria Area Drone Videography Page 14

### D. The Reasons Why Granting RodneyNordstrom Request Would Be In The Public Interest; That Is, How It WouldBenefit The PublicAsA Whole. Granting the present Petition will further the public interest by allowing Rodney Nordstrom to safely, efficiently) and economically perform aerial video and photographyofreal estate, safety inspection, special events, film sets, and landscape
over certain areas ofthe United States. Additionally, use ofthe DJI Phantom 3 Advanced UAS will decrease congestion of the NAS, reduce pollution, andprovide significant benefits to the economy. Notably, the benefits ofRodney Nordstrom's proposed operation ofthe DJI Phantom 3 Advanced UAS will be realized without implicating anyprivacy issues. 1. The Public Will Benefit From Decreased Congestion OfThe NAS. The DJI Phantom 3 Advanced UAS is batterypowered and serves as a safe) efficient, and economical alternative to the mannedaircraft traditionally utilized to obtain aerial imagery. By reducing the amount ofmanned aircraft needed to perform aerial acquisitions, an exemption allowing the use ofa DJI Phantom 3 Advanced UAS will reduce the amountofmanned aircraft in the NAS, reduce noise and air pollution, as well as increasethe safety oflife and property in the air and on the ground. Furthermore, by reducing the number ofmanned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft willbe reduced. The DJI Phantom 3 Advanced UAS does not require an airport to takeoff
or land. Likewise, a reduction ofmanned aircraft conducting aerial video and photography missions would result in fewer aircraft that mustbe handled by air traffic control during the ground, takeoJf, departure, arrival, and landing phases offlight operations. 2. The Public Will Benefit From The Safety And Efficiency OfThe DJI Phantom 3 Advanced UAS Conducting aerial acquisitions with the DJI Phantom3 Advanced UAS, instead ofmanned aircraft, will greatly benefit the publicby drastically reducing the levels ofair and noise pollution generatedduring traditional aerial video and still photography flight operations. Byusing battery Rodney Nordstrom for Peoria Area Drone Videography Page 15power and electric motors, the DJI Phantom 3Advan::ed.UAS produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized for aerial video and photography, whileburning approximately 20-30 gallons per hour ofleaded aviation fuel. The DJI Phantom 3 Advanced UAS, while reducing the carbon footprint ofaerial acquisitions, also eliminates noise pollution, asthe UAS are propelledby battery powered electric motors, rather than an internal combustion engine.By using the DJ1 Phantom 3 Advanced UAS to perform aerial acquisitions; the substantial risk to life and propertyin the air and on the ground, which is usually associated withtraditional manned aircraft flight operations, will be substantiallyreduced or completely eliminated. Aside from the lack offlight crew members located onboard the aircraft, the DJI Phantom 3 Advanced UAS (weighing approximately 2 pounds 11 with a length of 16 inches, widths of 16 inches, and with no fuel on board), has less physical potential forcollateral damage to life and property on the ground, and in the air, compared to the manned aircraft thattypically conduct similar operations (weighing approximately 6,000 pounds with a wingspan ofapproximately 42 feet,
a length of34 feet, and a fuel capacity of 180 gallons). 3. PerformingAerial Video and Photography Operations WithThe DJI Phantom 3 Advanced UAS Will Benefit TheEconomy. In addition to being safe and efficient, the DJI Phantom3 Advanced UAS is also an economical alternative to using manned aircraft toconduct similar aerial operations. As such, operation ofthe DJI Phantom 3 Advanced UAS will allow United States based companies,like Peoria Area Drone Videography, to remain competitive and contribute to growth oftheU.S. economy. Specifically, with the rising cost ofaviation fuel and theEnvironmental ProtectionAgency ("EPA") regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternativetechnology in order to remain competitive. Operating the battery powered DJI Phantom 3 Advanced UAS is one such technology that not only allows Rodney Nordstrom for Peoria Area Drone Videography Page 16companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operational cost ofa traditional 

### manned ' aircraft. By operating the DJI Phantom 3 AdvancedUAS, companies such as \ Peoria Area Drone Videography, can remain competitive andprofitable, and ' therefore, provide greaterjob stability to employees and contractors, which will ultimately contribute to growth ofthe U.S. economy. Improvedfinancial performance ofU.S. companies, through commercial use ofthe DJI Phantom 3 Advanced UAS, provides a stable workforce that increases consumer spending; improves local, state, and federal tax revenues; and allows companies to invest in research and development in orderto remaincompetitive both in the United States and abroad. 4.There Are No Privacy Issues. Similar to the manned aerial acquisition flight operations that havebeen conducted for decades, Rodney Nordstrom proposed operation ofthe DJI Phantom 3 Advanced UAS will not implicate any privacy issues. Specifically, the DJI Phantom 3 Advanced UAS will be operated onlyin compliance with operating documents (i.e., the Aerial Drone MediaOperations Manual, Monthly Maintenance Log, and DJI Phantom 3 Advanced Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including theminimum altitude requirements of 14 C.F.R. 

### §91.119.

E. 

### The Reasons Why Granting The Exemption Would Not AdverselyAffect Safety, Or How The Exemption WouldProvideA Level OfSafety At Least Equal To That Provided By The Rule From Which RodneyNordstrom Seeks Exemption. 1. ReasonsWhy The DJI Phantom 3 Advanced UAS Meets The Conditions OfThe FAA Modernization and Reform Act of2012 (FMRA) Section 333.

In consideration ofthe size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, Rodney Nordstrom's operation ofthe DJI Phantom 3 Advanced UAS meets the conditions ofFMRA Section 333, and will not require Rodney Nordstrom for Peoria Area Drone Videography Page 17

# ..

an airworthiness certificate in accordance with 14 C.P.R. Part 21, Subpart H. Section 333 provides authority for a UAS to operate withoutairworthiness certification and sets forth requirements for considering whether a UAS will createa hazard to users ofthe NAS or the public, orotherwise pose a threat to national security.
Specifically, FMRA Section 333 states the following, in part: (a) In General.--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days afterthe date ofenactment ofthis Act, the Secretary of**~** Transportation shall determine ifcertainunmanned aircraft systems mayoperate safely in the national airspace system before completion ofthe plan and rule-making required by section 332 ofthis Act orthe guidance required by section 334 ofthisAct. (b) Assessment ofUnmannedAircraft Systems.--In making the determination under subsection (a), the Secretary shall determine, at aminimum-- (1) whichtypes ofunmanned aircraft systems, ifany,
as a result oftheir size, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line of sight do not create a hazard to users ofthe national airspace system orthe public or pose a threat to national security; and (2) whether a certificate ofwaiver, certificate of authorization, or airworthiness certification under section 44704 oftitle 49, UnitedStates Code, is required for the operation ofunmanned aircraftsystems identified underparagraph (1). (c) Requirements for Safe Operation.--Ifthe Secretary determines under this section that certain unmanned aircraft systems may operate safely inthe national airspace system, the Secretary shall establish requirements for the safe operation of Rodney Nordstrom for Peoria Area Drone Videography Page 18such aircraft systems in the national airspace system. In seeking this exemption, Rodney Nordstrom submits that the DJI Phantom 3 Advanced UAS can operate safely in the NAS pursuantto FMRA Section 333,
as demonstrated by: (a) the characteristics ofthe DJI Phantom 3 Advanced UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.



### The Specifications OfThe DJI Phantom 3Advanced UAS Demonstrate 

### Its Safe Characteristics. The DJI Phantom 3 Advanced UAS does not create ahazard to users ofthe NAS
orthe public, or otherwise pose a threatto national securityconsidering its size, weight, speed, and operational capability.

i. Technical Specifications OfThe DJI Phantom 3 Advanced UAS. The technical specifications ofthe DJI Phantom 3 Advanced UAS is set forth by the DJI Phantom 3 Advanced UAS Specifications and Data Sheet, attached hereto as Exhibit A.

ii. The DJI Phantom 3 Advanced UAS Autonomous Flight And Navigation Modes Enable The UAS To Remain WithinA Defined OperationalArea. The DJI Phantom 3 Advanced UAS may be operated in both manual and fully autonomous flight modes.
m. The DJI Phantom 3 Advanced UASAre DesignedForAutomatic Return To Home Point Or Hover In The Event OfLoss OfThe Control Link Or Navigation. When the Control Link is lost, the DJI Phantom 3 Advance UAS will remains stationary, in flight, for3 seconds or more. If, after 3 seconds, the DJI Phantom 3 Advanced UA Sdoes not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAwill return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoffposition and shutdown. A Rodney Nordstrom for Peoria Area Drone Videography Page 19complete description ofthe Failsafe Functions ofthe DJI Phantom 3 AdvancedUAS are set forth at pages 27 through 29 ofthe OJI Phantom 3 Advanced User Manual,**atta~hed** hereto as B.



### Flight Operations OfDJI Phantom 3Advanced UAS Are Limited To The Line OfSight OfA Certificated Pilot in Command With A SafetyObserver.

·Rodney Nordstrom will only utilize certificated pilots who possess a current and
1 valid UAV credential as a pilot in command (PIC) ofthe DJI Phantom 3 Advanced UAS. Additionally, a safetyobserver will assist all pilots during flight .time.


### Flights OfDJI Phantom 3 Advanced UAS Will Be Conducted Pursuant To Specific Operating Limitations. In seeking this exemption, proposes to commercially operate DJI Phantom 3 Advanced UAS for the special purpose ofconducting aerial video and photography over certain areas ofUnited States, pursuantto the following specific operating limitations:

1. Operations authorizedby this grant ofexemptionwill be limited to the following aircraft described in the operating documents, rotorcraft UASs weighingless than 55 pounds maximum gross weight: DJI Phantom 3Advanced UnmannedAircraft System. Proposed operations ofany other aircraft will require a new petition or a petition to amend this grant.

Rodney Nordstrom for Peoria Area Drone Videography Page20

## '

2. UAS operations under this exemptionwill be limited to conducting operations for the purpose ofaerial video and photography for homeowners, Realtors, homebuilders, contractors, home inspectors for use 

### in real estate marketing and real estateinspections. Additionally, aerial video and photography maybe conducted on occasional basis for special events and landscape photography, aerial mapping, surveying as deemed necessary.

3. The UAS may not be flown at an indicated airspeed exceeding 29 knots (15 m/s).

4. The UAS must be operated at an altitude ofno more than 200 (500 perthe User Manual) feet above ground level (AGL), as indicated by the procedures specified inthe operating documents unless a special request is made and approved byATC. All altitudes reported to ATCmust be in feetAGL.

5. The UAS must be operated within visual line ofsight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided byany device otherthan corrective lenses, as specified on the PIC'sFAA-issuedairman medical certificate.

6. The use offirst personview (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOScapability. The SO and PIC must be able to communicate verbally at all times.Electronic messaging ortexting is not permitted during flight operations. The PIC mustbe designated beforethe flight and cannottransfer his orher designation for the duration ofthe flight. The PIC must ensure that the SO canperformthe functions prescribed inthe operatingdocuments.

Rodney Nordstrom for Peoria Area Drone Videography Page 218. The SO must not perform any other duties beyond assisting the PIC withseeing and avoiding other airtraffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments.

9. The operating documents and the grant ofexemption must be accessible during UAS operations and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations contained inthe grant ofexemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant ofexemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator's responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitionsfor extension or amendment to the grant ofexemption. Ifthe operator determines that any update orrevision would affect the basis upon whichthe FAA granted the exemption, then the operator must petition for amendment to its grantof exemption. The FAA'sUAS Integration Office (AFS-80) may be contacted if questions arise regarding updates or revisions to the operatingdocuments.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be ina condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

11.Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement ofa flight critical component, must undergo a functional test flight. The PIC who conducts the
Rodney Nordstrom for Peoria Area Drone Videography Page 22functional test flight must make an entry in the aircraftrecords.

12. Thepre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered inthe relevant sections ofthe operatingdocuments.

13. The operator must follow the UAS manufacturer'saircraft/component, maintenance, overhaul, replacement, inspection, and life limitrequirements.

14. The operatormust carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents.Maintenance, inspection, alterations, and status ofreplacement/overhaul componentparts must be noted in the aircraft records, including total time in service, description ofwork accomplished, and the signature ofthe authorized person returning the UAS to service.

15. Each UAS operated under this exemption must comply with allmanufacturers Safety Bulletins.

16. The authorized person must make an entry in the aircraft record ofthe corrective action taken against discrepancies discovered between inspections.

17. The PIC mustpossess at least 5 hours training with an Dronepilot certified by Peoria Area Drone Videography before being allowed to be assigned any solo flights with a SO.

18. The operator may not permit any PIC to operate unless the PIC meetsthe operator's qualificationcriteria and demonstrates the abilityto safely operate

Rodney Nordstrom for Peoria Area Drone Videography Page 23

### ...

the UAS in a manner consistent with how the UAS will be operated underthe exemption, including evasive and emergency maneuvers andmaintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. 

### § 61.5l(b). Flights for the purposes oftraining the operator's PICsare permitted under the terms ofthe exemption. However, training operations may only be conducted during dedicated training sessions. Duringtraining, proficiency, and experience-buildingflights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate theUA with appropriate distance from nonparticipants in accordance with 14 C.F.R. 

### § 91.119.

· 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. 

### §

1.1. All operations must be conducted under visual meteorological conditions (VMC). Ifflight at night is required, a special request will be made at the FAA office closest to proposed area ofoperations. Flights under special visual flight rules (SVFR) are notauthorized.

20. The UAmay not operate within 5 nautical miles ofan airport referencepoint as denoted on a current FAA-published aeronautical chart unless a letterof agreement with that airport's management is obtained, and the operationis conducted in accordance with a NOT AM as required by the operator'sCOA. The letter ofagreement with the airport management mustbe made availableto the Administrator uponrequest.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. Ifthe UA loses communications or loses its GPS signal, it must return to a predetermined location within the planned operating area and land or berecovered
Rodney Nordstrom for Peoria Area Drone Videography Page 24in accordance with the operatingdocuments.

23. The PIC must abort the flight in the event ofunpredicted obstaclesor emergencies in accordance with the operatingdocuments.

24. The PIC is prohibited from beginning a flight unless (considering windand forecast weather conditions) there is enough power to fly at normalcruising speed to the intended landing point and land the UA with 25% batterypower

· remaining.

25. All operations shall be conducted in accordance with airspace requirementsin the ATO issued COA including class ofairspace, altitude level andpotential transponder requirements.

26. All aircraft operated inaccordance with the exemptionmustbe identified by serial number.

27. Before conducting operations, the radio frequency spectrum used for operation and control ofthe UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agencyrequirements.

28. The documents required fewer than 14 C.F.R 91.9 and 91.203 must be availableto the PIC at the Ground Control Station ofthe UAS any time the UAS is operating. These documents must be made availableto theAdministratoror any lawenforcement official upon request.

Rodney Nordstrom for Peoria Area Drone Videography Page 2529. The UAS mustremain clear and yield the right ofway to all mannedaviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device orvehicle.

31. Flight operations must be conducted at least 500 feet from allnonparticipating persons (persons other than the PIC, SO, operator trainees or essentialpersons), vessels, vehicles, an'd structures unless:
a. Barriers or structures are present that sufficiently protectnonparticipating persons from the UA and/or debris in the event ofan accident. The operator must
ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within500 ' feet ofthe UA, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures wherethe owner/controller ofsQ.ch vessels, vehicles or structures has grantedpermission and the PIC has made a safety assessment ofthe risk ofoperating closerto those objects and determined that itdoes not present an undue hazard, and;
c. Operations nearer to :the PIC, SO, operator trainees or essentialpersons do notpresent an undue hazard to those persons per§ 91.119(a).

32. All operations shall be conducted overprivate or controlled-accessproperty withpermission from the land owner/controller or authorized representative.Permission from land owner/controlleror authorized representative will beobtained for each flight to be conducted.

33.Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area must be reported to the National Transportation SafetyBoard (NTSB) perinstructions contained ontheNTSB.Web site: www.ntsb.gov.

Rodney Nordstrom for Peoria Area Drone Videography Page 26

## ..

2. Reasons Why An Exemption From The Requirements OfSection 61.113(a) And (b) Would Not Adversely Affect Safety. Rodney Nordstrom submits that the equivalent level ofsafety established by Section 

### 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 3 Advanced UAS unless that PIC has demonstrated, by meeting minimum flight- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 3 Advanced UAS in a manner consistent with the exemption, includingevasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Rodney Nordstrom's proposed area ofoperations, and the operating limitations setforth- above; the parallel nature ofprivate pilot aeronautical knowledge requirements to those ofcommercial pilot requirements (See ExemptionNo. 11062); and the ainnanship skills necessary to safely operate the DJI Phantom 3 Advanced UAS, Rodney Nordstrom submits that the additional manned airmanship experience ofa commercially certificated pilot would not correlate to the airmanship skills necessary for Rodney Nordstrom's specific proposed flight operations. The FAAhas previously granted relieffrom Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos.11062, 11063,11064,11065,11066,11067,11080,11109,11110,11112, 11136,11138,11150,11153,11156,11158,11159,11160, 11161).


### 3. Reasons Why An Exemption From The Requirements OfSection 91.7(a) Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.7(a) will be maintained because prior to every flight, Rodney Nordstrom will ensure that the DJI Phantom 3 Advanced UAS is in an airworthy condition based upon the UAS's compliance with its operating documents and as stated in the conditions and limitations herein. Additionally, the FAAhas previously granted relieffrom Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g.
Rodney Nordstrom for Peoria Area Drone Videography Page 27ExemptionNos.ll062, 11063,11064,11065,11066,11067,11080,11109,111101 11112, 11136,11138,11150,11153,11156,11157,11158,11159,11160, 11161).


### 4. Reasons Why An Exemption From The Requirements OfSection91.121 Would Not Adversely Affect Safety. The equivalent level ofsafety established by Section 91.121 will be maintained because the altitude information ofthe DJI Phantom 3 Advanced UAS will be provided to the PIC via GPS equipment and a radio communications telemetry datalink, which downlinks from the UAto the GCS for active monitoring ofthe flight path and altitude. This altitude information, combined with Rodney Nordstrom's operation ofthe DJI Phantom 3 Advanced UAS within visual line ofsight, at or below 500 feetAGL, will ensure a level ofsafety equivalentto Section 91.121. The altitude information will be generated by GPS equipment installed onboardthe aircraft. Prior to each flight, a zero altitude initiationpoint is automatically established by the UASs at ground leveL The FAAhas previously granted relieffrom Section 91.121 specific to UAS,in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062,11063,11064,11065,11066,11067,11080,11109,11112,11136,11138, 11150,11153,11156,11157,11158,11159,11160, 11161). 

### 5. Reasons Why An 

### Exemption From The Requirements OfSection91.15l(b) Would Not Adversely Affect Safety. A grant ofthis exemptionwould ensure an equivalent level ofsafety established by 14 C.P.R. Section 91.151(b) as a result of(1) the technical specifications ofthe DJI Phantom 3 Advanced UAS; (2) the limitations on the proposed flight operations; and (3) the location ofthe proposed flight operations. Accordingly, Rodney Nordstrom will ensure that he will safely operate the battery powered DJI Phantom 3 Advanced UA during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. Here, as inExemptionNo. Ill09, the technical specifications ofthe DJI Phantom 3 Advanced liAS; the Jjmitations on the proposed flight operations; andthe location oftheproposed Rodney Nordstrom for Peoria Area Drone Videography Page 2 8operations, 

### will ensure an equivalent levelofsafety established by 14 C.P.R. Section 91.151(b). Furthermore, safety will be ensured as the 

### DJI Phantom 3 Advanced UAS provide audible and visual warnings to the PIC at the GCS when the UAS experiences low batteryvoltage, the first warning occurring at approximately 33%remaining battery power, and again at approximately 10% remaining batterypower. At the critically low battery level, the DJI Phantom 3 UAS will descend andland automatically. Significantly, previous exemptions granted by the FAAconcerning Section 91.151 establishthat safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted formanned aircraft to operate at less than the minimums prescribed in Section 91.151,including ExemptionNos. 2689, 5745, and 10650. Moreover, the FAAhas previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all materialrespects, to thosepresented herein (e.g. ExemptionNos. 8811, 10808, 10673, 11042, 11062, 11063, 11064,11065,11066,11067,11080,11109,11110,11136,11138,11150,11153, 11156, 11157, 11158, 11159, 11160, 11161).
6. Reasons Why An Exemption From The Requirements OfSections 91.405{a), 91.407{a){l), 91.409{a){l) & {a)(2), And 91.417(a) & {b) Would Not Adversely Affect Safety.
In seeking this exemption, Rodney Nordstrom submits that the equivalent levelof safety withregard to the regulatory maintenance and alterationrequirements established by Sections 9L405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will bernet because RodneyNordstrom will use trained technicians to perform maintenance, alterations,
orpreventive maintenanceonthe UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the Rodney Nordstrom AerialOperations Manual, Monthly Maintenance Log, and DJI Phantom 3Advanced Instruction Manual). Furthermore, Rodney Nordstrom will document and maintain allmaintenance records for the DJI Phantom 3 AdvancedUAS.

Phantom 3 Advanced UserManual is attached hereto as .Exhibit B & D; a copy oftheDJI Phantom3 Advanced UAS Maintenance LOG is attached hereto as Exhibit C. Rodney Nordstrom for Peoria Area Drone Videography Page 29Since the DJI Phantom 3 Advanced UAS will be inspected asprescribed by the operating documents, Rodney Nordstrom will maintain the equivalent level ofsafety established by 

### Sections 91.405(a), 91.409(a)(l), and 91.409(a)(2). Acopy ofthe DJI Likewise, the exemption sought will not adversely affect safety because Rodney Nordstrom

### will
use trained techniciansto performmaintenance, alterations or preventivemaintenance onthe UAS using the methods, techniques, and practicesprescribed bythe operating documents. Purthennore, the exemption sought would maintain an.equivalent level ofsafety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance ofthe DJI Phantom 3 Advanced UAS will beperformed by trainedtechnicians. Maintenance will be documented and maintained utilizing the monthly maintenance log. Significantly, previous exemptions granted bythe PMconcerning Sections 91.405(a), 91.407(a)(l), 91.409(a)(1) 

### & (a)(2), and 91.417(a) 

### & (b) establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. In consideration ofRodney Nordstrom's proposed operating limitations, the operating documents, and the technical aspects ofthe DJI Phantom 3 Advanced UAS, Rodney Nordstrom submits that safety will not be adversely affected bygranting exemption from 14 C.P.R. Sections 91.405(a), 91.407(a)(l) and (a)(2), 91.409(a)(2),and 91.417(a) and 

### (b). The PAAhas previously granted reliefspecific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063,11064,11065,11066,11067,11080,11109,11110,11112,11136,11138, 11150, 11153,11156,11157,11158,11159,11160, 11161).


### 7. The FAAMay PrescribeAny OtherConditions ForSafe Operation. In accordance with Section 333 ofthe PAAModemization and ReformAct of2012 (PMRA) and 14 C.P.R.§ 21.16 entitled Special Conditions, Rodney Nordstrom requests that the P AAprescribe special conditions for the intended operation ofthe DJI Phantom3 Advanced UAS, which contain such safety standards thatthe Administrator finds necessaryto establish a level ofsafety equivalent to that established by 14 C.P.R. Part 21, Subpart H, and 14 C.P.R §§ 61.113(a) 

### & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a) (1), 91.409(a)(l) & (a)(2), and 91.417(a) & 

### (b). Such special conditions will permit safe Rodney Nordstrom for Peoria Area Drone Videographyoperation ofthe UAS for the limited purpose ofcondu'cting aerial video and photography
over certain areas ofthe United States for compensation orhire. 

### FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, orotherwise pose a threat to national security; and further, provides the authority for such UAS to operate**witho~t** airworthiness certification in accordance with any requirements that must be established for the safe operation ofthe UAS in theNAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. 

### §21.16, for operation ofthe DJI Phantom 3 Advanced UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriatesafety standards, due to the novel or. unusual design features ofthe aircraft. Section21.16, entitled Special Conditions, states the following: Ifthe FAAfinds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriatesafety standards for an aircraft, aircraft engine, orpropeller because ofa novel or unusual design feature ofthe aircraft, aircraft engine or propeller, he prescribes special conditions and amendmentsthereto for the product. The special conditions are issued in-accordance with Part 11 ofthis chapterand contain such safety standards for the aircraft, aircraft engine or propeller asthe FAAfi!lds necessary to establish a level ofsafetyequivalent to that established in the regulations. See 14 C.F.R. 

### §21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. 

### § 21.16, theFAA mayprescribe special conditions for Rodney Nordstrom's intended operation ofthe DJI Phantom 3 UAS, which contain such safety standards that theAdministrator finds necessary to establish a level ofsafety equivalentto that established by 14 C.F.R. Part21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), and 91.417(a) &(b).



### F. ASummaryThat Can Be Published In The Federal Register, stating: The Rules Froni Which Rodney Nordstrom Seeks Exemption: Rodney Nordstrom seeks exemption from the requirements of 14 C.F.RSections 61.113(a)&(b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b).
Rodney Nordstrom for Peoria Area Drone Videography Page ·31A BriefDescription OfThe Nature OfThe Exemption Rodney Nordstrom Seeks: This exemption will permit Rodney Nordstrom to commercially operate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial video and photography over certain areas ofthe UnitedStates.



### G. Any Additional Information, Views, OrArguments Available To Support Rodney Nordstrom's Request. This Petition is made pursuant to the FAA Modernization and ReformAct of2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, Rodney Nordstrom request for exemption may begranted pursuant to the authority ofFMRA Section 333 and 14 

### C.P.R. Part ll,as set forth above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users ofthe NAS orthe public, or otherWise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification. As discussed in detail above, Rodney Nordstrom will operate the DJI Phantom 

### 3 Advanced UAS safely in the NAS, without creating a hazard to usersofthe NAS, orthe public, or otherwise pose a threat to nationalsecurity.

CONCLUSION

As set forth herein, Rodney Nordstrom seeks an exemption pursuant t9 14

### C.P.R. § 11.61 and Section 333 ofthe FAAModernization and ReformAct of2012 (FMRA), which will permit safe operation ofthe DJI Phantom 3 Advanced UAS commercially, without an airworthiness certificate, for the limited purpose ofconducting aerial video and photographyover certain areas ofthe United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAAModernization and ReformAct of2012, while also advancing the interests ofthe public, by allowing RodneyNordstrom owner of Peoria Area Drone Videography to safely, efficiently, and economically operate the DJI Phantom 3 Advanced UAS commercially within theNAS. WHEREFORE, in accordance with the FederalAviation Regulations and the FAA

Rodney Nordstrom for Peoria Area Drone Videography Page 32

# ..
Modernization and Reform Act of2012, Section 333, Rodney Nordstrom respectfully requests that the Administrator grant this Petition for an exemption from the requirements of14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151 (b), 91.40S(a),91.407(a)(l), 91.409(a)(l) & (a)(2), and 91.417(a) & (b), and permit Rodney Nordstrom to operate the DJI Phantom 3 Advanced UAS commercially for the purpose ofconducting aerial video and photography ofReal Estate Properties (for homeowners, realtors, home builders, home contractors and 

### I or home inspectors for real estate marketing and inspectionofhome exteriors)
as well as filming ofspecial events, film sets, landscape as well as aerial mapping, surveying over certain areas ofthe United States.

Dated: November 3, 2015



### Rodney Nordstrom P 661 S. Ridgeview Peoria, IL 61602 Tel: 309-369-7067 Email: jurydoctor@sbcglobal.net

Rodney Nordstrom for Peoria Area Drone Videography Page 33Appendixes: A- OJI Phantom 3 Advanced/Technical S'pecifications B
- OJI Phantom 3 Advanced Manufacturer's User Manual C- OJI Phantom 3 Advanced Technical Specifications 0
- Monthly Maintenance Log

/

Rodney Nordstrom for Peoria Area Drone Videography

### APPENDIX-A
DJI PHANTOM 3 ADVANCED/TECHNICAL SPECIFICATIONS Rodney Nordstrom only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with.ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be setto limit flight to no higher than a predetermined and set altitude as well as limit flight to a predeterminedand set distance. In addition, DJI software provides real-time altitude and location informationto the PIC via the linked monitor (smart phone/tablet devices)

Rodney Nordstrom for Peoria Area Drone VideographyAPPENDIX-B 

### DJI Phantom 3 Advanced Manufacturer's User Manual http://www.dji.com/product/phantom-3/download
Manual can be downloaded from above link. Manual was not included to conserve space.

Rodney Nordstrom for Peoria Area Drone Videography

### APPENDIX-C DJI PHANTOM 3 ADVANCED TECHNICAL SPECIFICATIONS

AIRCRAFT 

### Weight (IncludingBatteryAnd Propellers) 1280 g Diagonal Size (lncludingPropeUers) 5.90 rnm MaxAscentSpeed 5 m/s Max DescentSpeed 3 m/s HoverAccuracy

• Vertical:+/- lOcm 

### • Horizt)ntal: +/- 

### l1n

Max Speed 16 m/s (ATTI mode, no wind) MaxAltitudeAbove Sea Level 6000m OperatingTemperature GpsMode GPS/GLONASS

GIMBAL 

### ControllableRange Pitch -90° to+30° StabiJization 3-axis (pitch, roll,yaw)

Rodney Nordstrom for Peoria Area Drone Videography

### REMOTE CONTROLLER 

### OperatingFrequency 2.400 GHz-2.483GHz MaxDistance 2000m (outdoors and unobstructed) Video OutputPort USB OperatingTemperature Battery 6000 mAh 

### LiPo 2S Mobile DeviceHolder For tablet orphone Receiver Sensitivity(!%Per) -101 dBm ±2 dBm TransmitterPower(Eirp)

• FCC: 20dBm • CE: 16 dBm
Working Voltage 1.2 A @7.4V

BATTERYCHARGER 

### Voltage 17.4

# v RatedPowerPhantom3 Advanced lOOW

Rodney Nordstrom for Peoria Area Drone Videography 3ff

### INTELLIGENT FLIGHTBATTERY Capacity 4480 mAb Voltage 15.2

## v BatteryType LiPo 48 Energy 68Wh NetWeight 365g Max FlightTime Approximately 23minutes OperatingTemperature Max ChargingPower 

### lOOW

Rodney Nordstrom for Peoria Area Drone Videography 39

# .UAS



### ~r~

SoftwareUp,dates Airframe Engines Propellers CameraGimbal LandingGear Vibration Dampenin Other: 

### APPENDIX-D MONTHLY MAINTENANCE LOG


### Pssue

**9~er~tten**

### &.

.

**Ml§,'ktll~nan~@C!Ill.eotetJ:**



### Rodney Nordstrom month: Yter:

**·M;;~te~ee** 

## .••

**~** 

## Pei&ilm6Gm': · J?rilllt & 

### S:igm:

Peoria Area Drone Videography 661 S. Ridgeview Peoria, IL 61604 Tel: 309-369-7067 Email: j

### urydoctor@sbcglobal.net

Rodney Nordstrom for Peoria Area Drone Videography 40